Date Published: 05/03/2019
|GDPR Lawful Basis for Processing
Assessing product eligibilityAs a lender, we match your personal and financial circumstances to lending criteria. In order to do this, we collect information either directly from you or through an introducer you have approached.
We will assess your general eligibility for our products by undertaking a number of checks with credit reference agencies and fraud prevention agencies.
We require your personal information so that we can identify loan options
available to you.
It is also in our legitimate interests, when you approach us, to undertake a number of checks to assess your eligibility for a loan against lending criteria
Our use of your personal information is necessary to take steps to enter into a contract with you or perform a contract: for example, to assess your creditworthiness and sustainable affordability of any credit obligations you may undertake, or to conclude a loan agreement with you or obtain a guarantee and indemnity from you if you are to guarantee a Lifestyle loan.
We have a regulatory obligation to assess whether you will meet our lending criteria for a loan and to ensure you do not over-commit yourself. Our vulnerability checks are also designed to protect your vital interests.
In some cases, we must undertake these checks to comply with a legal obligation, for example under anti-money laundering regulations.
In carrying out this initial assessment, we may use automated decision systems that enable us to speed up our assessment. However, if we do this, you can ask us to assess your application manually if you wish.
Maintaining records of your application
For legal, regulatory and administrative purposes we shall retain your personal information securely on our systems until there is no longer any requirement to retain it.
We have legal and regulatory obligations in respect of identifying fraud,
money laundering and
financial crime. As a business regulated by the Financial Conduct Authority,
we also have regulatory
We will also retain your information in other circumstances where we have a legitimate basis for doing so, such as record keeping, dealing with any enquiries or complaints from you and internal administration.
Keeping you up-to-date
The lenders on our panel products and services, they have available, will change over time.
We would like to keep in touch with you, whether you have taken out a loan with one of the lenders on our panel, or where we have been unable on this occasion to provide you with any suitable options.
Where you have applied for a loan, we may contact you to keep you up to date
with products and
services which may be of interest.
It is in our legitimate interests to do this, but of course you can tell us you would prefer us not to contact you by clicking on this link, firstname.lastname@example.org and providing us with your full name, contact number (s) and postcode, so we can action this for you
You have the right to opt out, regarding the future processing of your information. Opting out will not affect the lawful basis for processing of your data before you opted out.
In order to do this, please use any of the preferred methods of communication belowby post, to the postal address
Unit G5, Frome Business Park, Manor Road, Frome, BA11 4FN by telephone on 0330 0889 764 by email using email@example.com
There are different ways in which we obtain your dataFrom our website, if you complete our online application form If you telephone us to make a loan application Certain Lenders and Credit Brokers may pass your information to us, should they be unable to assist you with a loan. Please note that if this is the case, we will provide you with the identity of these individual firms.
The categories of data that we collect are as follows:Collecting and recording details about any health issues you may have which may affect your understanding of our application process. Our vulnerability checks are designed to protect your vital interests. Loan amount you require Your name and date of birth Partner name and date of birth (should you request a joint application) Address Details Employment Details Partner Employment Details (should you request a joint application) Mortgage Details or Tenancy Details Bank Details Other Income & Expenditure you might incur Your Financial Status I.e. Bankruptcy, Defaults & Missed Credit Payments, Count Court Judgements, Individual Voluntary Arrangement and Debt Management Plan
In order to process your application, we will perform a credit check on you with one or more Credit Reference Agencies (“CRAs”).
To do this, we will supply your personal information to CRAs and they will give us information about you. The information we will supply to the Credit Reference Agency will include information from your application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
The information which we and other organisations provide to the credit reference and fraud prevention agencies may be supplied by credit reference agencies to other organisations and used by them to perform similar checks.
If you are making a joint application or tell us that you have a spouse or financial partner, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before completing the application.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail which is accessible from each of the three CRAs.
We will continue to exchange information about you with CRA’s while you have a relationship with us. We will also inform the CRA's about your settled accounts. If you borrow and do not repay in full or on time, CRA's will record the outstanding debt. This information may be supplied to other organisations by CRA's.
The credit reference agencies used by us and our panel of lenders are Experian, Call Credit and Equifax.
Clicking on any of these three links will also take you to the Credit Reference Agency Information (CRAIN) document:TransUnion formerly known as Call credit https://www.transunion.co.uk/crain Equifax https://www.equifax.co.uk/crain Experian https://www.experian.co.uk/crain/
We may make searches of records held at fraud prevention agencies. If you give us false or inaccurate information and we confirm fraud, we will record this and may pass this information to fraud prevention agencies and other organisations to prevent fraud and money laundering. Law enforcement agencies may access and use this information.
We share personal data for crime and fraud prevention and the apprehension and prosecution of offenders.
We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
The information which we, other organisations and fraud prevention agencies provide to the credit reference and fraud prevention agencies about you and your financial associates may be supplied by the credit reference and fraud prevention agencies to other organisations and used by us and them for example to:Prevent fraud and money laundering, Verify your identity if you or your financial associate applies for other facilities including all types of insurance applications and claims, Assist other organisations to make decisions on credit and credit related services or other facilities, Trace your whereabouts and recover debts that you owe, Managing credit and credit related accounts and other facilities; and Undertake statistical analysis and system testing Checking details on applications for credit and credit related accounts or other facilities. Checking details of job applicants and employees
We may provide your personal information to anyone who hosts or maintains data centres, service platforms and other infrastructure and systems on behalf of us, where your personal information is processed and/or stored;
Except as described above, we will not disclose your personal information to Third Parties, without your consent.
Please be reassured that we will not release your information to third parties beyond our firm and its trading styles for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to data.
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or re-organisation.
We may also disclose personal information about you to the extent required by Law, Court Order, by Government order or decree
However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
As part of the services offered to you through this website, the information which you provide to us may be transferred to companies in countries outside the European Union (“EU”).
If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
If we process your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
By submitting your personal data, you’re agreeing to this transfer, storing or processing of your data.
We may use automated decision systems once your loan application is submitted to us. This is done in an effort to ensure that we are able to assess your eligibility for a loan against our panel of lenders criteria and ultimately provide you with the loan options available for you to consider.
Your principal rights under data protection law are:the right to access your information the right to rectification the right to erasure where records are no longer required the right to object to Processing where this use is based on our legitimate interests the right to restrict processing the right to complain to a supervisory authority
a) The right to access your information
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to that personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, at your request, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
b) The right to rectification
You have the right to have any inaccurate personal data that we hold about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
c) The right to erasure, where records are no longer required
In some circumstances you have the right to the erasure of your personal data without undue delay.
Those circumstances include:the personal data that we hold is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; the personal data that has been unlawfully processed
However, there are exclusions of the right to erasure.
The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
If your information has been passed over to lender(s) on our panel you will need to contact them requesting to exercise your right to erasure, regarding the information they hold about you.
d) the right to object to Processing where this use is based on our legitimate interests
To the extent that we may contact you to keep you up to date with services that may be of interest to you and this is based on our legitimate interests to do so, you have the right to unsubscribe to this service at any time. Opting out of this will not affect the lawful basis for processing of your data before you opted out.
This does not automatically mean that we need to erase your personal data, and in most cases, it will be preferable to suppress your details. Suppression involves retaining just enough information about you to ensure that your preference not to receive future communications on products or services is respected.
If your information has been passed over to lender(s) on our panel you will need to contact them requesting to exercise your rights to object to any processing, regarding the information they hold about you and any other consent you may have provided to them over the use of your information.
e) The right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data.
Those circumstances are:you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but we require personal data for the establishment, exercise or defence of legal claims; you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data.
However, we will only otherwise process it, for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
f) The right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection, the Information Commissioners Office.
Information Commissioners Office Contact Details
You can call their helpline on 0303 123 1113 (local rate – calls to this number cost the same as calls to 01 or 02 numbers).
We would welcome the opportunity to investigate any complaint you have, you can do this by:-Emailing us at: firstname.lastname@example.org Writing to us at Unit G5, Frome Business Park, Manor Road, Frome, BA11 4FN Telephone: 0330 0889 764
In order to process your loan application, we will require you to complete our online loan application. We require this information to assist you in finding you loan options. If you do not provide us with this information, we will be unable to carry out our services to you as a lender.
We work closely with third parties for example, credit brokers and credit reference agencies who may have contacted you to assist with your loan enquiry. These third-party companies may have been unable to assist you with your enquiry and may have noticed that we could possibly assist you, in this case, they will have passed your information to us, ensuring that you have been informed and have agreed for your information to be processed in this way.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Below is a table of information which lists all cookies used on our website.
A Google Analytics cookie, which keeps track of the
number of times, a visitor has been to the site, when their
first visit was, and when their last visit occurred.
A Google Analytics cookie, which creates a
timestamp of the exact moment when a visitor enters a site.
A Google Analytics cookie, which creates a
timestamp of the exact moment when a visitor leaves the site.
Used for reporting in Google Analytics classifying
A Google Analytics cookie which tracks where the
visitor came from, what search engine was used, what link was
clicked on, what keywords used, and where in the world the site
was accessed from.
The pixels used, are not set up to collect personally identifiable data such as names, email addresses. As such the pixel tag can’t be used to track anything back to an individual.
Third party media owner pixels – e.g. DBM, Quantcast etc
We have some of these pixels on our site, and these are used for the following techniques:Building an audience (retargeting, lookalike, exclusions) Optimising To model the data Reporting
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.